Web accessibility in the public sector: Royal Decree 1112/2018

Which rules apply

Directive (EU) 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies was transposed in Spain by Royal Decree 1112/2018 of 7 September.

It applies to the General State Administration, the autonomous communities (Spain's regions), local authorities, the institutional public sector and other bodies that the Royal Decree brings within its scope.

What it requires

1. Meet the accessibility requirements. The technical reference is the EN 301 549 standard (UNE-EN 301 549 in Spain), which refers to WCAG levels A and AA for the web.
2. Publish an accessibility statement that follows the model in Commission Implementing Decision (EU) 2018/1523, review it at least once a year and make it available from every page through a link labelled “Accesibilidad” (Accessibility).
3. Provide a feedback mechanism so that anyone can report accessibility problems, request information in an accessible format or make a complaint. Replies must be given within 20 working days at most.
4. Allow complaints to the Unit responsible for accessibility (Unidad responsable de accesibilidad) when the reply is not satisfactory or does not arrive in time.
5. Review accessibility regularly, with automated tests and also with a manual review by experts.

Some content is excluded, such as certain older office files and media content, online maps if the essential information is provided in an accessible way, third-party content that the body does not control, and archives that are no longer edited. Check the text of the Royal Decree for the exact conditions.

How it is monitored

Commission Implementing Decision (EU) 2018/1524 sets out the monitoring methodology, with two types of review:

• Simplified monitoring: automated tests on a large sample of websites. It can only detect failures.
• In-depth monitoring: it checks all the requirements, with manual testing, on a sample of pages that includes complete processes.

In Spain, the Web Accessibility Observatory (Observatorio de Accesibilidad Web) carries out the simplified monitoring of public websites.

The statement, step by step

The accessibility statement has a fixed structure: commitment and scope, compliance status, non-accessible content, preparation of the statement, feedback and contact details, enforcement procedure and optional content. We explain it in detail on our accessibility statement page, and you can prepare a draft with our free generator.

How SiteNorma helps you

The public sector regulatory profile adapts each analysis to these obligations:

• It checks that the “Accesibilidad” (Accessibility) link appears on every page analysed.
• It warns you if the statement is more than 12 months old.
• It checks that the feedback form is available.
• It suggests a sample of pages for the manual review, based on the methodology in Commission Implementing Decision (EU) 2018/1524.
• It generates the statement with the official model, based on your compliance matrix.

SiteNorma does not replace the expert review that the rules require: it gives you the method and the tools to carry it out and document it.

Official texts

• Royal Decree 1112/2018 of 7 September, in the BOE (Spain's Official State Gazette)
• Directive (EU) 2016/2102, on EUR-Lex
• Commission Implementing Decision (EU) 2018/1523, on EUR-Lex
• Commission Implementing Decision (EU) 2018/1524, on EUR-Lex

General information, not legal advice. Last reviewed: 25 September 2026.